Speciality Paper and the Future
Thursday 19 November 2015
Jori RingmanSustainability Director
CEPI@RBJori
EU Policy framework for food contact
General EU legislation
Regulation EC 1935/2004 ‐Framework Regulation on materials and articles intended to come into contact with food
Regulation EC 2023/2006 ‐Good Manufacturing Practice for materials and articles intended to come in contact with food
CEPI guidance (self‐regulation)
[Link to the publication embedded in the image]
“Food contact materials must not transfer their components into the foods (migration) in unacceptable quantities.”
EU Policy framework for food contact
Legislation on specific materialsRegulation EU 10/2011 – plastic materials and articles intended to come into contact with foodRegulation EC 450/2009 ‐ active and intelligent materials and articles intended to come into contact with foodRegulation EC 282/2008 ‐ recycled plastic materials and articles intended to come into contact with foodsDirective 2007/42/EC ‐materials and articles made of regenerated cellulose film intended to come into contact with foodsDirective 84/500/EEC – approximating EU countries' laws on ceramic articles intended to come into contact with foods
On‐going process to decide what material to harmonise next EU expected to decide mid 2016
CEPI has, as many other stakeholders and major member states, indicated the need to prioritise paper and board in contact with food
Legal uncertainty complicates prompt reactions where issues arise, limiting assurance of consumer safety and increasing reputational risk
There are negative impacts on recycling activity of the sector, in the absence of clear rules
Functioning of the internal market is highly questionable
There is a negative impact on many sectors in the EU, notably the food industry
1
2
3
4
5
Paper‐based packaging suffers a non‐level playing field and a loss of competitiveness compared to already harmonised food contact materials
Why a harmonised measure?
Currently, in the absence of a harmonised measure
Juncker’s motto
I want to be serious about being big on big things and small on small things.
Jean‐Claude Juncker, President of the European Commission10 September 2014
Packaging Generation, EU‐28 (2012)
31,527
15,101
4,559
15,732
12,213
Paper & Board
Plastics
Metal
Glass
Other
• Paper and board is the leading packaging material, 39.9% of all packaging generated in EU (Eurostat, 2012), more than Nr 2 and Nr 3 combined.
• Of the recycled packaging materials available on the market, paper and board continues to account for the majority of demand (CEPI 2014).
Paper & Board 39.9%
(Million tonnes)
Secondary fibres: 74.4%
Primary fibres: 25.6%
EU food and packaging ‐ global players
Source: EY “Unwrapping thepackaging industrySeven factors for success”
The food and drink industry is the largest manufacturing sector in the EU in terms of turnover (14.9%) and value added (12.9%). It still has growth potential in exporting to the growing global middle‐class.
Europe holds a share of 34% of the global packaging markets.
Food and drink, on average, have 51% and 18% shares respectively.
EU rules are often preferred by developing economies as a template – in the absence of such rules, also export markets will fragment.
Packaging often can be assembled with input from various EU countries
Without Packaging no Cassis de Dijon!
Without packaging, free movement of goods would not be possible.
The free flow of goods and services along the supply chains to the consumers throughout the EU increases choice and drives the economy.
It provides the EU businesses with a large home market in which they can improveefficiency and build capacity to competeglobally, resulting in jobs and growth for Europe’s citizens.
This is best ensured with harmonisation.
(Illustrative example ‐ Original images copyright by Briottet S.A.S.)
Self‐regulation ensures safety – but not internal markets
Europe’s paper industry is concerned about the lack of a harmonised measure for paper and board packaging in the EU. Whereas the industry has taken up the responsibility to self‐regulate the sector to ensure a high level of consumer protection, the lack of harmonisation comes with a cost.
This is of an importance as paper and board are a leading packaging material and with the aim of circular economy and bio‐based green growth, the sector has a potential for adding more value and jobs in the European economy whilst ensuring a high level of consumer protection and food safety.
RENEWABLEBIODEGRADABLE
RECYCLABLE
Me
You
Self‐regulation ensures safety – but not well perceived
In the absence of a harmonised measure, some Member States have taken or are taking action to regulate the material nationally which hamper the functioning of the internal market and creates different levels of consumer protection across the EU.
This is a concern recently repeated by several NGOs. Now also the European parliament is taking up this issue!
This trend of national regulation is now fast accelerating as the Commission is perceived taking no action.
Case of Italy
It is clear to see that this situation translates to a loss to 1. those manufacturing paper and
board as they have a de facto reduced market access;
2. for those buying paper and board for converting since they can procure with reduced competition in supply;
3. this translates to higher cost to those using packaging and finally to consumers.
This, naturally, is not supporting the jobs&growth agenda.
The Ministerial Decree of 21 March 1973 on Hygienic
Requirements for Packaging, Containers, and Utensils Intended To Be
Used in Direct Contact with Food and Substances for
Personal Use
Innovation in Regulation?
Specific Measure•What!•Resulting from the Roadmap and evaluation processes• Setting essential rules, long‐life
Paper and Board Guidance•How!•Drafted jointly – adopted by the Commission•Easy to update as science evolves
Good Manufacturing Practice•How! •Required by Regulations (EC) No 1935/2004 & No 2023/2006•Tailor‐made to context, adopted by industry
Framework Regulation 1935/2004
Responsibility
Common rules
Clear objectives
Self‐regulation
Flexibility
Room for innovation
Internal market
Same safety standard
Agility
Experience tells us where to make a difference
REQUIREMENTS
Virgin fibres Recycled fibres
Consumer packaging
Transport packaging
Work to be done!
Consumers are not exposed to health risks related to paper and board packaging. Nevertheless, industry wants to see a world‐class standard for consumer safety applied uniformly across the EU.
The European Commission equally holds the key to ensuring internal markets, growth and jobs; growing trend of non‐EU regulation is increasing compliance costs and where it limits offer on the market, increasing cost to consumers.
One harmonised measure would greatly simplify and modernise the fragmented European regulatory framework!
BIO
Circular
Low Carbon
CEPI aisbl / Confederation of European Paper Industries250 Avenue Louise, Box 80, B‐1050 BrusselsTel: +32 2 627 49 11 / Fax: +32 2 624 81 [email protected] [email protected]
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Thank you!